October 29, 2009

Cato Journal is America’s leading free-market public policy journal. Every issue is a valuable resource for scholars concerned with questions of public policy, yet it is written and edited to be accessible to the interested lay reader. Clive Crook of The Economist has called it “the most consistently interesting and provocative journal of its kind.”

Always happy to contribute at least a little something to the public policy debate as it concerns climate change, your humble staff at World Climate Report are pleased announce the inclusion of our article “Scientific Shortcomings in the EPA’s Endangerment Finding from Greenhouse Gases” in the latest issue (Fall 2009) of the Cato Journal.

Hopefully it will prove to be valuable resource for scholars and laypersons alike during the continued debate concerning our national energy policy and how it may (or may not) relate to the issue of global climate change.

On April 24, 2009, the U.S. Environmental Protection Agency issued a finding of “proposed endangerment” from climate change caused by six greenhouse gases, with the largest contributions to warming resulting from emissions of carbon dioxide and methane (EPA 2009a).

The EPA also referred to this document as a “proposed finding” in response to a 2007 decision by the U.S. Supreme Court, Massachusetts v. EPA, which empowered the EPA to make such a finding for greenhouse gases under existing law. This was the Court’s interpretation of Section 202 (a) of the Clean Air Act Amendments of 1990.

In Proposed Endangerment, the EPA requested comments “on the data on which the proposed findings are based, the methodology used in obtaining and analyzing the data, and major legal interpretations and policy considerations underlying the proposed findings” (EPA 2009a: 18890).

We answered the EPA’s request in a filing on June 23, 2009 (Michaels, Knappenberger, and Davis 2009). This article details some of the most relevant findings in our response. In general, we found that Proposed Endangerment suffered from systematic errors that were inevitable, given that the way in which the EPA chose to determine the required background science had to result in both biased and outmoded climate science. In addition, the EPA made grand and sweeping assumptions about human adaptation to climate that are of such illogic as to invalidate the entire study. We believe that these systematic errors call into question any attempt on the EPA’s part to subsequently issue regulations on greenhouse gas emissions. Other entities that may use the EPA’s document as a basis for emissions reductions will be using similarly incomplete science and be subject to severe and public criticism. This conclusion has obvious implications for upcoming negotiations in Copenhagen in December 2009, on a replacement for the Kyoto Protocol.